In
their Jan-06 Risk Assessment the CPSC proves the average adult will
absorb a daily dose of .802 mg of Antimony, .081 mg Boric Acid, and .073 mg
DBDPO (Deca) from flame proof mattresses.

(It's True! See CPSC
Table 16 below) All three are acute poisons and two cause cancer. (Most
people do not want themselves or their children to absorb any amount of
poisons from their mattresses every day, to avoid the one in one million
risk of dying in a mattress fire.)

Plus,
Children under age five excluded from risk assessment. The CPSC assumes all these children will be protected by a
vinyl sheet over their mattresses due to bedwetting problems, and that this
will protect them from exposure to these known acutely toxic chemicals.
There are no labeling requirements. Parents will never know their new
mattresses contain toxic chemicals.

Unlike other flame
retardants that we initially think are non-toxic like Asbestos, and later
find them harmful, we already know these are acutely toxic and cancer
causing.

Antimony:
Quote from College Chemistry Textbook:“Antimony
resembles Arsenic very closely;the difference in
its behavior being almost entirely accounted for by the fact that antimony
is slightly more metallic.” This helps explain why it is so poisonous.
Quotes from ATSDR a division of the CDC on Antimony: “An increase in the
number of spontaneous abortions, disturbances in menstruation, failure to
conceive, May cause heart to beat irregularly or stop. … Chronic Exposure:
Prolonged or repeated exposure may damage the liver and the heart muscle."
“In long-term studies, animals that breathed very low levels of antimony had
eye irritation, hair loss, lung damage, and heart problems. Problems with
fertility were also noted.” "Two studies reported lung tumors in rats
exposed to relatively low levels of antimony trioxide." Antimony tends to
accumulate in the liver and gastrointestinal tract.” The CDC cannot
determine a safe level of Antimony exposure because: “At the lowest exposure
levels tested, the adversity of the effects was considered to be serious.”
On cancer risks of Antimony even the CPSC admits:
“The cancer effects are cumulative. Every exposure contributes to the
overall lifetime risk of developing cancer.”

Boric Acid, also used
as Roach Killer, is a known reproductive and developmental toxin, a
known respiratory irritant, Demonstrated injury to the gonads and to the
developing fetus. high prenatal mortality, Neonatal children are unusually
susceptible. There are already 6,463 U.S. cases of Boric Acid poisoning each
year. One human exposure study showed reduced sperm counts and reduced
sexual activity in humans.

DBDPO, Deca, is in
the family of PBDE’s, is known to bioaccumulate, is linked to cancer, and
groups are trying to get it banned.

The CPSC has completed
extraction studies that show the percentage of FR chemicals contained in
various mattress flame barriers. (See CPSC Table 1 below, It shows 7 of 13
barriers contain Antimony, and 5 of 13 contain Boric Acid) They have also
completed leaching and migration studies that prove these chemical reach
the surface of our mattresses through the sheets, to be absorbed by our
bodies, and base the above poison absorptions calculations on this data.

All mattresses sold in
California, and one half of mattresses sold nationwide already contain FR
chemicals for this law. Why do all flame proof mattress manufacturers try to
say they don’t use chemicals, when the CPSC proves them wrong? Because
almost no one wants to sleep in known toxic and cancer causing chemicals, to
avoid the one in one million risk of dying in a mattress fire.

The CPSC has
received over 800 public comments against this law when they would normally
only receive about twenty from interested parties on most issues. This
generated an article in the Washington Post titled: “Fire Resistant Mattresses Ignite Fear of Chemicals.”

Many Doctors
oppose this law:9 M.D.’s (many of them
prominent), a Medical School Professor PhD who studies toxicology,
2 PhD Chemists, and a PhD Professor of Mathematics who researches and
teaches probability theory. One M.D. calls it “Ethically Unacceptable”
to put any person at this risk of poisoning and cancer, much less our entire
population. Another M.D. says: “If the CPSC pushes this law forward, they
need to change their name.” And another M.D. says: “I know many chemically
sensitive people who do not tolerate treated mattresses. And how many are
intolerant who don't know why they can't sleep or feel bad?”

Yet the CPSC rebuts and
ignores all these comments just as they rebut the comments of their
independent reviewer. The CPSC is required by law to get an independent
review of the risk assessment justifying this law. The reviewer, TERA.org,
found serious problems including: Children under age five were excluded
from the risk assessment. The CPSC assumes all these children will be
protected by a vinyl sheet over their mattress, and therefore not absorb as
much toxic chemical. Of course, there are no labeling requirements and
parents will never know their mattress contains toxic chemicals, or that
their child is receiving a daily dose of poison.

Another very serious
problem develops when the reviewer points out the CPSC should coordinate
their assumptions of the safe levels of absorption of poisons with other
agencies. The CPSC again rebuts them claiming their assumptions are correct
and that coordinating with other agencies would not make a substantial
difference.

New Info, EPA Proves
Mattresses Toxic

I wrote to the CDC asking
what level of Antimony exposure is safe. I got a reply from the CDC: “ATSDR
has not derived a chronic MRL [Minimal Risk Level] for antimony. However,
the U.S. EPA chronic oral reference dose for antimony is 4E-4 mg/kg/day.”
This is .0004 mg/kg/day, or 4/10,000’s of a milligram/ per kilogram of body
weight/ per day. This is a far different number than the CPSC assumption of
a safe level of 2.3 mg/kg/d. In fact, it is 5,750 times more than the EPA
minimal risk number. It also changes everything and proves our antimony
absorption from flame proof mattresses is unsafe by 27.5 times. In a proper
risk assessment, this would stop this law.

Comparing these numbers
to the CPSC assumptions in their table 16, tab d, p 45, shows:

Parameter

Antimony (CPSC
Assumptions)

Antimony (CDC/ATSDR/EPA
numbers)

Difference CPSC/EPA

ADD Total
(mg/kg/d) (Average Daily Dose)

0.011

0.011

ADI mg/kg/d
(Acceptable Daily Intake)

2.3

.0004

5,750

Hazzard Index, HI
(numbers below one are considered safe)

.005

27.5

5,500

CPSC tests prove we will
absorb 0.011 mg/kg/d of Antimony from new flame proof mattresses. The only
question is what is a safe level? The CPSC says 2.3 mg is safe while the EPA
says only .0004 is a safe level. If we accept the EPA number it proves new
mattresses are toxic by 27.5 times more than the safe level.

The CPSC risk assessment
repeatedly states the hazard index should be below one, meaning anything one
or above is unsafe. Clearly a hazard index of 27.5 is very unsafe for our
entire population to sleep in. The science of toxicology, when given the
correct assumptions, proves flame proof mattresses are unsafe for human
exposure.

I question what else in
the CPSC risk assessment is invalid? We might absorb a lot more poison than
they predict. It seems clearly designed to justify and force this law
through. It does not meet the standards of a good risk assessment, young
children and other sensitive populations were not included. Many more
chemicals are also used to flameproof mattresses that were not considered or
studied. For instance the CPSC preferred melamine resin system is made from
the reaction of melamine and formaldehyde, and contains free formaldehyde,
but formaldehyde was not studied. And as TERA pointed out a good risk
assessment should include our exposure from other sources, i.e. upholstered
furniture. This was again rebutted even though the CPSC is in the final
stages of requiring these same chemicals in upholstered furniture in another
open flame law about to be enacted. Additionally, the CPSC is about to enact
another FR law covering our top of the bed items including mattresses pads,
comforters, and pillows, which will again require these same toxic
chemicals. Then, the only time we won’t be absorbing poisons is while we are
standing up.

The U.S. already uses 1.2
Billion pounds of flame retardants every year, and the Chemical
Manufacturers Association estimates this saves up to 960 people annually.
The CPSC estimates of saving up to 272 people annually from this law alone
seem overly optimistic. In the 350 fire deaths where the mattress or bedding
was the first item to ignite, 80% of the time the bedding ignited first, not
the mattress. But it does not matter if it saves 30 or 300. We are putting
300 million people, our entire population, at risk to sleep in known toxic
chemicals, and receive a daily dose of poison.

It seems likely this law
will kill more than 300 sensitive people annually. But what if any one of
these chemicals proves toxic over many years? Perhaps many of our children
might be dumber than we are, or it could be catastrophic. If one third of
our mattresses are toxic, it will harm 100 million people, If only 15% of
our mattress prove toxic, it will be 45 Million people harmed. If only 1%
prove toxic, it is still 3 million people harmed.

Even with all its risks,
and their risk analysis proven wrong, it seems the CPSC can’t see the forest
for the trees, and will likely enact this law right after Valentine’s Day,
on Thursday February 16, 2006.

The CPSC studies have
proven me right

It is no longer just me
saying poisonous chemicals are used to flame proof mattresses, and major
mattress manufacturers saying they don’t use chemicals. Now the CPSC Table 1
proves which chemicals and their percentages are used. There are no chemical
free systems that can pass this blow torch open flame test.

It is no longer just me
saying these toxic chemical can leach out and get us while mattress
manufacturers say they are chemically bound and can’t get out. The CPSC
migration studies prove these chemicals leach through the sheets and are
absorbed by our bodies. In fact the CPSC proves we will get a daily dose of
poisons of .802 mg of Antimony, .081 mg of Boric Acid, and .073 mg of DBDPO,
every day for the rest of our, our children’s, and our grandchildren’s
lives.

The EPA has proven CPSC
safety assumptions wrong. The EPA has also proven CPSC exposure and
absorption calculations of poison absorbed from flame proof mattresses will
exceed toxic levels by 27.5 times.

We hope you will report
this story. With all mattresses sold in California required to be flame
proof, and half of new mattress sold nationwide already flameproof in
anticipation of the new law, millions and millions of people are already
sleeping in and absorbing a daily dose of poisons. The rest of us will
eventually sleep in and absorb these poisons. People have a right to know
the truth. You don’t have to take my word for the truth. The truth and proof
is in CPSC Tables 1 and 16.

Please give me a call, I
can give you a lot more information including contact information for the
many doctors and others who oppose this law and chemical use, and contact
information for people who claim their new flame proof mattresses made them
sick.

Sincerely

Mark Strobel

Who is Strobel?
Mark Strobel is founder and owner of Strobel Technologies, a 32 year old
company that manufactures specialty mattresses including Supple-Pedic, a
patented visco foam mattress with patented "Lever Support System" or "Air
Lever System," and Airbeds, Waterbeds, and Latex beds, all the newer
technologies compared to innerspring mattresses. Strobel in not a Sealy or
Serta, but does sell nationwide and worldwide and maintains permanent
wholesale showrooms at the major furniture markets including the largest at
High Point NC. Strobel’s Supple-Pedic mattress is seen nationally regularly
on CBS’s show “The Price is Right.” Unable to find a chemical free and safe
system for his beds, Mark Strobel was appalled at the toxic chemicals
required to flameproof mattresses. The more he researched the issue, the
more concerned he became that the risks could prove catastrophic and harm
hundreds of millions of people. Mark eventually started the group
PeopleForCleanBeds.org that generated over 800 public comments against the
law, and generated news for the issue with many newspapers and TV stations.
It was the many public comments that generated a news article in May by the
Washington Post, and this article was reprinted by many newspapers across
the country. Mark has tried to fight the issue with the CPSC directly, even
sending them bottles of Boric Acid Roach Killer powder, and this earned him
a CPSC audit of his company’s compliance with the 1973 mattresses cigarette
ignition law. The CPSC even purchased a Strobel mattresses at retail for
testing under this law, (perhaps an attempt to get him?) but Strobel
mattresses comply with the law without chemicals and this audit is still
being worked out. This slowed down his direct contact for a while but he
latter resumed it by sending the CPSC numerous emails and letters of new
facts he continued learn. The CPSC even has the newest data of the EPA
proving their risk assessment wrong. In spite of it all, it appears the CPSC
will pass this new mattress fire law.

Melamine
Resin Barriers are
made from the reaction of Melamine and Formaldehyde, and contain free
Formaldehyde, but these barriers were not tested for Formaldehyde content.

FORMALDEHYDE MSDS:
"POISON! DANGER! SUSPECT CANCER HAZARD. MAY CAUSE CANCER. Risk of cancer
depends on level and duration of exposure. VAPOR HARMFUL. HARMFUL IF INHALED
OR ABSORBED THROUGH SKIN. CAUSES IRRITATION TO SKIN, EYES AND RESPIRATORY
TRACT. STRONG SENSITIZER. MAY BE FATAL OR CAUSE BLINDNESS IF SWALLOWED.
CANNOT BE MADE NONPOISONOUS."
http://www.jtbaker.com/msds/englishhtml/F5522.htm

Si is Silicon,
which was not tested for either. It also has health risks: “Silicon may
cause chronic respiratory effects. … Inhalation will cause irritation to the
lungs and mucus membrane. Several epidemiological studies have reported
statistically significant numbers of excess deaths or cases of immunologic
disorders and autoimmune diseases in silica-exposed workers. These diseases
and disorders include scleroderma, rheumatoid arthritis, systemic lupus
erythematosus, and sarcoidosis. Recent epidemiological studies have reported
statistically significant associations of occupational exposure to
crystalline silica with renal diseases and subclinical renal changes.
Crystalline silica may affect the immune system, leading to mycobacterial
infections (tuberculous and nontuberculous) or fungal, especially in workers
with silicosis Occupational exposure to breathable crystalline silica is
associated with bronchitis, chronic obstructive pulmonary disease (COPD) and
emphysema. … Lung cancer is associated with occupational exposures to
crystalline silica

Ammonium Polyphosphate
is the only other chemical used to flame proof mattresses not listed above.
Not as much is know of how toxic this chemical is to sleep in, but it is
doubtful sleeping in and absorbing this fertilizer could be good for us. The
CPSC has shown large amounts of this chemical leach from mattresses.

As
you can see above 7 of the barriers contain Antimony and 5 contain Boric
Acid. It is no wonder there are no labeling requirements for the FR
chemicals used in mattresses. Which of the above systems would you choose to
sleep in? We don’t think any of these systems are safe, they all have risks.

We
keep hearing about inherently flame resistant fibers from the CPSC and
mattress manufacturers. These inherently flame resistant fibers have
chemicals blended with the fiber as the fiber is made. The only true
inherently flame resistant fiber is fiberglass, and even that is blended
with chemicals to make a barrier as you can see in the table above.

We
are glad to see the CPSC proved all the fire barriers contain toxic
chemicals, maybe the truth can be told to the public.

The new risk in our
modern world is our exposure to toxic substances. The National Safety
Council says 17,550 people die each year from“Accidental
poisoning by and exposure to noxious substances," this number now
exceeds deaths in car accidents.

Notice: The
statements and questions contained in my writings are not intended to convey
allegations regarding any particular company, person, or association.
Readers should conduct their own investigation of a company or association
or person to ascertain the particular policies, practices, and motivations
of that entity. I have reported what I believe to be true and correct to the
best of my knowledge and opinion at the time of its writing in a free speech
effort to avert a public health disaster.